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Background
On January 1st, 2020, the United Kingdom started the exit process from the European Union and entered into a Transition Period. As the often titled “Brexit” transition period ends on December 31st, 2020, the United Kingdom will no longer be a part of the European Union Customs Union and the European Single Market. Relevant free trade agreements will not be applicable to the UK from January 1st, 2021.
For the chemical industry, an independent chemical regulatory framework, namely the UK REACH, will be officially implemented in the UK next year, as the EU REACH regulations and supervision mechanism will not be applicable then. It means that enterprises manufacturing, selling, importing, and distributing chemicals in the UK and the EU will have to face two REACH systems separately.
Interpretation of the UK REACH Transitional Measures
Speaking at the CRAC 2020, Mr. Simon Johnson from the UK’s Department of Environment, Food and Rural Affairs introduced the impact of the implementation of the UK REACH on the industry and how enterprises to comply with the new management system and maintain their business in the UK and the EU. According to Mr. Johnson’s speech, actions have been taken when establishing UK REACH to minimize the impact on the chemical supply chains, including
Mirroring EU REACH as much as possible
Providing transitional measures, etc.
However, there are still obstacles for enterprises to make sure they are in compliance with the new UK REACH requirements, including
Complex transitional measures for enterprises with different trade roles,
Implementation of Northern Ireland Protocol, etc.
What follows are the key points of Mr. Johnson’s speech, which focus on the interpretation of the transitional measures and help enterprises better understand the UK REACH and comply with relevant compliance requirements.
For UK registrants and EU registrants who already hold EU REACH registration numbers, 120 days and 300 days are respectively given to submit basic information to avoid interruption of production, sales, and import activities.
The implementation of the UK REACH will result in role changes of enterprises. For example, British companies used to be downstream users under the EU REACH will become importers and assume the registration responsibilities after the implementation of the UK REACH. The 300-day transition period will help companies adapt to the role changes and new compliance responsibilities.
The establishment of the UK REACH also adopts stakeholders’ advice. Depending on tonnage bands and hazard profile of chemicals, companies will have 2, 4, or 6 years beginning after those 300 days (October 28th, 2021) to complete full registrations, instead of the original 2 years for all.
If the trade of a chemical depends on the registration number of the UK registrant, in order not to interrupt trade to the EU market, it is necessary to help EU importers complete the EU REACH registration before December 31st, 2020, or transfer the registration number to the only representative based in the EU.
Conclusion
The adjustment of the transition period deadline will help companies’ better digest and understand this new regulation. Under the premise of fully understanding the supply chain, companies can take appropriate measures to maintain access to the UK market and the EU market and reduce trade frictions as much as possible for their compliance responsibilities. ChemLinked would like to remind stakeholders that there are less than 40 days left to the implementation of the UK REACH so time is of the essence to learn and prepare for it.
* The materials (video and ppt) of the presentation are available now. You can click here to register our CRAC-HCF Forum and then go to the download section of the Live Conference Hall to get them if there is a need.
